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Page 1: Harmonisation of Definitions of Homelessness for …...Harmonisation of Definitions of Homelessness for UK Official Statistics: A Feasibility Report PAGE 7 Due to the devolved nature

Harmonisation of Definitions of Homelessness for UK Official Statistics: A Feasibility Report PAGE

Harmonisation of Definitions of

Homelessness for UK Official

Statistics: A Feasibility Report February 2019

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Harmonisation of Definitions of Homelessness for UK Official Statistics: A Feasibility Report PAGE 2

About the GSS Harmonisation Team

The GSS Harmonisation Team maintains and develops a range of harmonised principles (definitions,

survey questions, guidance for administrative data and guidance to be used when presenting outputs).

Harmonisation is about making the data Government collects and the statistics we produce as useful

as possible. The GSS Harmonisation Team aims to ensure commonality in the use of definitions,

survey questions, administrative data and in the presentation of outputs across the Government

Statistical Service (GSS). Ensuring comparability across the GSS is important as it maximises the

power of data and analyses without compromising quality.

We work closely with the Good Practice Team, Quality Centre and Methodology Advisory Service, as

part of the GSS Best Practice and Impact Division.

Acknowledgements

We would like to acknowledge the input from all users and producers of homelessness statistics and

collectors of homelessness data who contributed to this report. This report also benefitted from

consultations with members of the third sector and academia. Organisations involved are listed in

Annex A.

We would particularly like to thank colleagues at the Ministry of Housing, Communities and Local

Government, Office for National Statistics, Scottish Government, Welsh Government, Department for

Communities Northern Ireland and Northern Ireland Housing Executive, for their input during our

consultations and their feedback on this report.

Contact

To contact the GSS Harmonisation Team please email [email protected]

Or visit: https://gss.civilservice.gov.uk/guidances/harmonisation/

Icon made by Good Ware from www.flaticon.com

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Executive Summary 4

1. Introduction 6

2. Definitions of homelessness across the UK

2.1 Legal definitions of homelessness across the UK

2.2 Current legal definitions and how they differ

8

8

9

3. Statistical definitions and data collection methodology

3.1 Statutory homelessness and temporary accommodation statistics

3.2 Rough sleeping statistics

12

12

14

4. Feasibility of harmonising UK definitions of homelessness

4.1 Conclusion

16

16

5. Opportunities for improving users’ understanding of the comparability of homelessness statistics

5.1 Statistical publication guidance

5.2 Conceptual framework for homelessness

18

18

18

6. Recommendations 19

7. Next steps 21

8. Annex A: Organisations that contributed to this report 22

9. Annex B: Definitions of priority need

9.1 Annex B1: Definition of priority need - The Housing (Homeless Persons) Act 1977

9.2 Annex B2: Definition of priority need - The Housing (Wales) Act 1996

9.3 Annex B3: Definition of priority need - The Housing (Northern Ireland) Order 1988

23

23

24

25

10. Annex C: Definitions of intentionally homeless

10.1 Annex C1: Definition of intentionally homeless - The Housing Act 1996

10.2 Annex C2: Definition of intentionally homeless - The Housing (Wales) Act 2014

10.3 Annex C3: Definition of intentionally homeless - Housing (Northern Ireland) Order 1988

26

26

27

28

11. Annex D: Other Government departments’ definitions of homelessness 29

12. Annex E: Third sector and academic definitions of homelessness 30

13. Annex F: References 31

Contents

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Homelessness affects a wide range of people, covering not just people sleeping rough, but also

those in temporary accommodation, sleeping temporarily at friends houses, living in unfit dwellings

and those threatened with homelessness. Statutory homelessness and rough sleeping are the two

main concepts of homelessness discussed in this report, however, other types of homelessness

were explored as part of this research.

This report investigates the feasibility of harmonising UK definitions of homelessness, and

evaluates methods for improving users’ understanding of the comparability of UK homelessness

statistics.

Homelessness statistics differ across the countries of the UK because homelessness and housing

are devolved matters. Homelessness data is often collected through administrative systems which

were built using definitions based on each country’s legislation, and so data are not currently

comparable.

As differences exist, there should be a sufficient explanation as to what these differences are and

to what extent homelessness statistics can be compared. However, current explanations are

inconsistent and do not provide a thorough commentary on the comparability of homelessness

statistics across the UK. As a result, users perceive existing explanations as “confusing and

incoherent”[1]

.

To address the problem of inconsistency and support users of homelessness statistics, the GSS

Harmonisation Team has explored the feasibility of harmonising the definitions of homelessness

for official statistics. The team researched definitions of homelessness used for statistical,

operational and academic purposes. Additionally, we explored devolved homelessness legislation

and how this underpins data collection techniques in each UK nation. Lastly, we explored ways to

improve users’ understanding of the comparability of homelessness statistics across the UK and

outlined recommendations for producers.

We have concluded that it is not possible in the short term to develop a consistent definition of

homelessness for UK official statistics, due to substantive differences in the administrative data

systems and legal definitions of homelessness. As such, our recommendations are as follows:

1. Develop more comprehensive guidance on the processes and definitions of

homelessness used in each country’s statistical publications, which is consistent

across publications. The GSS Harmonisation Team will work with UK producers of

homelessness statistics to agree consistent guidance for all four UK nations which can be

included in their statistical publications.

2. Create a separate, user-friendly paper on UK comparability of homelessness statistics

which will include a conceptual framework for homelessness. This standalone report will

include a description of UK comparability and UK homelessness publications will link to it. It

will also contain a conceptual framework which will allow users to visualise the different

definitions of homelessness currently used for official statistics and how these fit together.

Executive Summary

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3. In the long-term, it is important that across the Government Statistical Service we

consider what are the big questions around homelessness in the UK and whether

some of that requires coordinated working across each UK country, and to consider

how data can be collated to answer those questions. Statutory homelessness data is

driven by legislation in each UK nation, as is appropriate in a devolved context. However,

statistics producers can still continue to explore alternative ways to improve UK comparability.

Consideration should be given to how the barriers to harmonisation that we have identified

could be overcome, including an assessment of the costs and resources associated with

providing users with information on the size of the differences, or guidance on how to make

adjustments to obtain comparable estimates. To assist in this longer-term goal to improve the

harmonisation of UK homelessness statistics, we have outlined the key differences between

the sources and the reasons for those differences throughout this report.

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Country Government Department Statistics

England Ministry of Housing, Communities and Local Government

• Applications for support from households that are homeless or threatened with homelessness

• The outcomes of these applications • Numbers of people sleeping rough • Households in temporary accommodation

England Public Health England • Housing situations of those undergoing treatment for drug and alcohol misuse

Scotland Scottish Government • Applications for support from households that are homeless or threatened with homelessness

• The outcomes of these applications • Numbers of people sleeping rough • Households in temporary accommodation

Wales Welsh Government • Outcomes of applications for support from households that are homeless or threatened with homelessness

• Numbers of people sleeping rough • Households in temporary accommodation

Northern Ireland

Northern Ireland Department for Communities/ Northern Ireland Housing Executive

• Applications for support from households that are homeless or threatened with homelessness

• The outcomes of these applications • Numbers of people sleeping rough

Since September 2017, the GSS Harmonisation Team has investigated the feasibility of developing

a harmonised UK definition of homelessness for use in statistics. This followed consultation with the

Ministry of Housing, Communities and Local Government (MHCLG) and the November 2017

publication of the Office for Statistics Regulation (OSR) systemic review of ‘Statistics on Housing and

Planning in the UK’. Based on feedback from over 60 users across 43 organisations, the review

highlighted several areas for improvement stating that “definitions of homelessness across the UK

differ due to devolved policy, and information about the extent of comparability is generally limited”[1]

.

Furthermore, the report concluded that users found a lack of clarity in existing advice about

comparability. A Cross Government Housing and Planning Statistics Work Programme was

published to address the areas for improvement identified in the OSR report. The work programme,

released in May 2018, stated that the GSS Harmonisation Team would:

“Conduct feasibility work and aim to develop a UK understanding of Homelessness definitions

as a first priority”[2]

.

Both the OSR report and the GSS Harmonisation Team have highlighted how, as homelessness is a

devolved issue, there are several definitions and important concepts used across the UK. Each

country in the UK is responsible for producing its own statistics on homelessness. However, despite

collecting data and producing statistics on similar concepts (as detailed in the table below),

definitions and data collection methods differ across the UK:

1. Introduction

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Due to the devolved nature of housing and homelessness matters across the UK, definitions do

vary, and currently there is insufficient guidance on how to compare the related statistics.

Furthermore, homelessness data is often collected through administrative data sources which are

also not currently comparable due to differences in legislative processes and systems.

To improve comparability and user understanding of the statistics, the GSS Harmonisation Team

has engaged with a wide range of stakeholders (see Annex A for details) to understand the

definitions in use (both the legal definition and the practical usage) and assess what can be done to

improve the clarity, comparability and transparency of homelessness statistics. This report covers

differences in legislation and data collection methods as well as an exploration of the definitions of

homelessness used across the UK. It discusses the feasibility of harmonising definitions of

homelessness across the UK, and recommendations for further work to improve the harmonisation

and user understanding of UK homelessness statistics.

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2.1 Legal definitions of homelessness across the UK

Housing legislation, which includes homelessness, differs across the four UK nations; some

differences in legislation are minor, whereas others significantly affect how homelessness statistics

are collected and produced. The Housing (Homeless Persons) Act 1977[3]

covered England, Wales

and Scotland and remained very similar across all three jurisdictions until the mid-1990s. This Act

was the first major piece of legislation on homelessness across the three nations. The Act adopted a

broad definition of homelessness including those who did not have accommodation and those with

accommodation where it was not reasonable for them to remain:

The Act introduced statutory duties on local authorities to assist those who are threatened with

homelessness within 28 days. Additionally, the housing authority would also have to satisfy whether

a person was in ‘priority need’ (see Annex B). Local authorities, by law, must provide housing to

some priority groups so an assessment is carried out to assess whether a person or household falls

under these requirements. ‘Priority need’ groups include but aren’t limited to; those with dependent

children, those made homeless by an emergency such as a flood or earthquake and people who are

vulnerable due to physical disability or mental health issue.

Since then, homelessness legislation has devolved and the most recent changes in this legislation

were the Housing (Wales) Act 2014[4]

, the Homelessness Etc. (Scotland) Act 2003[5]

and Homeless

(Abolition of Priority Need Test) (Scotland) Order 2012[6]

. English legislation has also undergone a

recent revision in the form of The Homelessness Reduction Act 2017[7]

.

The Housing (Homeless Persons) Act 1977[3]

1. A person is homeless for the purposes of this Act if he has no accommodation, and a person is to be

treated as having no accommodation for those purposes if there is no accommodation—

(a) which he, together with any other person who normally resides with him as a member of his family

or in circumstances in which the housing authority consider it reasonable for that person to reside with

him—

(i) is entitled to occupy by virtue of an interest in it or of an order of a court, or

(ii) has, in England or Wales, an express or implied licence to occupy, or

(iii) has, in Scotland, a right or permission, or an implied right or permission to occupy, or

(b) which he (together with any such person) is occupying as a residence by virtue of any enactment

or rule of law giving him the right to remain in occupation or restricting the right of any other person to

recover possession of it.

2. A person is also homeless for the purposes of this Act if he has accommodation but—

(a) he cannot secure entry to it, or

(b) it is probable that occupation of it will lead to violence from some other person residing in it or to

threats of violence from some other person residing in it and likely to carry out the threats, or

(c) it consists of a movable structure, vehicle or vessel designed or adapted for human habitation and

there is no place where he is entitled or permitted both to place it and to reside in it.

3. For the purposes of this Act a person is threatened with homelessness if it is likely that he will become

homeless within 28 days.

2. Definitions of homelessness across the UK

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Independent from the Housing Act 1977, in Northern Ireland, the Housing Executive Act (Northern

Ireland) 1971[8]

established the Housing Executive as a public authority and independent body; this

act was repealed but continued under the Housing (Northern Ireland) Order 1981[9]

. The Housing

(Northern Ireland) Order 1988[10]

describes homelessness similarly to the GB act in 1977, however

there are some differences.

The Housing (Northern Ireland) Order 1988[10]

1. A person is homeless if he has no accommodation available for his occupation in the United Kingdom or

elsewhere.

2. A person shall be treated as having no accommodation if there is no accommodation which he, together

with any other person who normally resides with him as a member of his family or in circumstances in which

it is reasonable for that person to reside with him—

(a) is entitled to occupy by virtue of an interest in it or by virtue of an order of a court, or

(b) has an express or implied licence to occupy, or

(c) occupies as a residence by virtue of any enactment or rule of law giving him the right to remain in

occupation or restricting the right of another person to recover possession.

3. A person shall not be treated as having accommodation unless it is accommodation which it would be

reasonable for him to continue to occupy.

4. Regard may be had, in determining whether it would be reasonable for a person to continue to occupy

accommodation, to the general circumstances prevailing in relation to housing in Northern Ireland.

5. A person is threatened with homelessness if it is likely that he will become homeless within 28 days from

the day on which he gives written notice to the Executive that he is threatened with homelessness.

2.2 Current legal definitions and how they differ

All four nations have introduced a legal duty to secure accommodation for certain homeless

applicants, but the type of applicant covered and assistance offered differs in each of the nations.

In Scotland, amendments were made to the Homeless (Scotland) Order 2012 which abolished the

‘priority need’ criteria. This means that the ‘priority need’ test is no longer part of the homeless

assessment and everyone assessed as being unintentionally homeless (see Annex C) was entitled

to settled accommodation. Additionally, since reforms in the Housing (Scotland) Act 2001[11]

,

legislation was amended to incorporate people who were threatened with becoming homeless.

Previously, local authorities had a statutory obligation to assist homeless applicants who were at

risk of homelessness within 28 days. Since 2001, local authorities have an obligation to help those

threatened with homelessness within 2 months, which in practice is 56 days.

In Wales, the Housing (Wales) Act 2014 (HWA 2014)[4]

, Part II, replaced the 1977 Housing

(Homeless Person’s) Act which was amended by the Housing Act 1996 Part VII[12]

, the Homeless

Persons (Priority Need) (Wales) Order 2001[13]

and the Homelessness Act 2002. The HWA 2014

came into force with an emphasis on early intervention introducing a statutory duty for help to be

provided to prevent applicants’ impending homelessness. The aim is to help people remain in their

own homes, or to find alternative accommodation quickly so that they do not experience actual

homelessness. Legislation dictates that local authorities must provide housing advice and

assistance to anyone in their local area regardless of whether a person is homeless or threatened

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with homelessness. Additionally, a statutory duty was placed on local authorities to help secure

accommodation for all applicants assessed as homeless and threatened with homelessness (known

as the homelessness relief duty). The relief duty can last for up to 56 days. If the relief duty has been

unsuccessful, local authorities must review their assessment and secure suitable accommodation for

those applicants who are assessed as being in ‘priority need’ (Annex B2) and are unintentionally

homeless (Annex C2).

In England, amendments by the Homelessness Reduction Act 2017 (HRA 2017) mirror the Welsh

approach, with an emphasis put on early intervention, the timescale of threatened homelessness

expanded to 56 days and a new prevention and relief scheme[7]

. Additionally, local authorities in

England have a duty to provide free advisory services to everyone in their district on preventing

homelessness, securing accommodation, clarity on the rights of homeless people and those

threatened with homelessness. Similar to the HWA 2014, the English legislation passed in 2017 still

recognises ‘priority need’ so therefore, non ‘priority need’ households are entitled to advice and

assistance only but not necessarily housing.

In Northern Ireland, the Housing (Northern Ireland) Order 1988[10]

, placed a duty on the Housing

Executive to secure accommodation for homeless people or those threatened with homelessness in

the next 28 days, and defined ‘priority need’ (Annex B3). The introduction of the Housing (NI) Order

2003[14]

sought changes to the definition of homelessness and the provisions regarding becoming

intentionally homeless (Annex C3) and introduced an additional requirement for the Housing Executive

to assess an applicant’s eligibility for housing assistance. The Housing (Amendment) Act (Northern

Ireland) 2010 introduced a statutory right to request a review of any decision as to a person’s eligibility

for assistance and suitability of offered accommodation[15]

. The amended act also required the Housing

Executive to formulate and publish a ‘Homelessness Strategy’ every five years.

Therefore, there are some differences in the definitions used in each of the four nations:

In English, Scottish and Welsh legislation people must be threatened with homelessness

within 56 days to be classed as ‘at risk’, whereas in Northern Irish legislation people

threatened with homelessness within 28 days are classed as ‘at risk’.

Legislation on ‘priority need’ is similar in Wales and Northern Ireland, but there are some

variations, such as the inclusion of “at risk of violent pursuit” in the Northern Irish

definition, and “a person who has served in the regular armed forces” in the Welsh

definition of priority need.

Legislation on ‘priority need’ in England is similar to both Wales and Northern Ireland and

includes “vulnerable as fled home because of violence / threat of violence” for both

domestic and non domestic abuse, and also “vulnerable as served in HM Forces”.

Priority need is not a requirement for initial assessments in England or Wales.

Scottish legislation does not include ‘priority need’ so there are fundamental differences

in who is eligible for housing between Scotland and the rest of the UK.

The differences in the legal definitions across the four nations matter because legislation forms the

basis for how and which data are collected. For instance, in Scotland (where there is no ‘priority need’)

everyone has the same right to housing and so will approach local authorities regardless of

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circumstance. In the other three nations, people who do not meet their criteria of ‘priority need’ may

be less likely to engage with local authorities. Since new Welsh legislation in 2014 and English

legislation in 2017, the priority need assessment now occurs at a later stage in the homeless

application process which may affect engagement with local authorities.

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Due to devolved legislation, data collection techniques for homelessness data are designed to

individually reflect the legislation in each country. Operational differences in collecting homelessness

information results in differences in homelessness statistics across the four nations.

Before the Homeless Reduction Act 2017, England used an aggregated local authority level system

called the P1E. Since new legislation came into effect in 2017, the P1E has been deemed no longer

fit for purpose. As the new legislation in England puts a statutory duty on local authorities to provide

help to all eligible homeless applicants regardless of ‘priority need’ or intentionality, a system which

incorporates this new information was required. In place of P1E, the Homelessness Case Level

Information Collection (H-CLIC), was established in April 2018 to collect administrative data to provide

much more detailed information on the causes and effects of homelessness as well as long term

outcomes and prevention of homelessness[16]

. The H-CLIC system has also been developed to

capture information on the circumstances and needs of homeless people seeking assistance. The

first statistics based on the H-CLIC system were published in December 2018.

In addition to MHCLG’s statistics on homelessness in England, Public Health England’s Alcohol and

Drug Treatment Monitor is also used to collect and publish statistics which includes information on

housing and homelessness. Public Health England (PHE) release an annual statistical publication on

the National Drug Treatment Monitor System (NDTMS)[17]

. This system is used to collect information

on people who are undergoing treatment for drugs and/or alcohol misuse. Two reports are published,

one for “young people” and one for “adults”. The NDTMS collects information on housing, amongst

many other topics, to understand the link between types of housing and the substance misuse

journey. Information on housing status is collected by clinicians and entered under three main

categories:

Although categories are included which relate to homelessness, the word ‘homeless’ is not used

when describing housing options. As the PHE NDTMS focuses on housing rather than just

homelessness, there is a category named “No housing problem” which would not be found on other

UK reports focussed solely on homelessness.

In Wales, the Welsh Government does not currently have a case level information system for

homelessness (like H-CLIC), however, local authorities are required to collect data on all households

who apply for homelessness assistance and to provide aggregate data to the Welsh Government. In

Wales, the information collected and published covers the outcomes of the various assistance duties

which may be owed to a household following their assessment under section 62 of the Housing

(Wales) Act 2014[4]

. It is possible for a single household to have up to three separate outcomes under

3. Statistical definitions and data collection methodology

Definition One: housing status[17]

1 No Housing Problem (Owner Occupier, Tenant, Supported housing/ hostel)

2 Current Housing Problem (Staying with friends/ family as a short-term guest, short term B&B, temporary accommodation by Local Authority, night winter shelter)

3 Urgent Housing Problem (Rough sleeping, night shelter on a night-by-night basis, emergency hostel, sofa surfing).

3.1 Statutory homelessness and temporary accommodation statistics

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this process depending on the results of the duty owed under the Act. The outcome of a duty is

recorded at each stage following the application for assistance with a housing assessment. The

outcome categories cover 1) prevention of homelessness 2) duty to help to secure accommodation

(relief) and 3) duty to secure suitable accommodation for those in priority need and unintentionally

homeless. Local authorities return this in an aggregated form to the Welsh Government, who produce

statistics for the quarterly and annual publications[18]

. As well as data on the outcomes of homeless

household applications, Wales also captures households housed in temporary accommodation at the

end of each quarter which includes details on the type of accommodation provided[18]

. Statistics on

statutory homelessness are released quarterly, and a more detailed analysis annually. Wales are

currently undertaking a study about the feasibility of introducing a case level information system for

homelessness.

Additionally, ONS published the first experimental official estimates of deaths of homeless people on

20 December 2018, covering the years 2013 to 2017[19]

. These estimates for England and Wales,

regions and combined authorities, were compiled from death registrations and information supplied by

coroners to ONS. The analysis included breakdowns by age, sex and cause of death. Due to homeless

people not being specifically identified or classified in the death registration data, it is not possible to

apply a precise a priori definition. However, the search strategies used identify people who were rough

sleepers or in emergency accommodation at or around the time of death. Further estimates at local

authority level for the same years were released on 25 February 2019.

In Scotland, four systems (HL1, HL2, HL3, and Prevent1, a similar system to H-CLIC), are used to

collect case level data on households applying as homeless to local authorities. If a household

presents themselves as homeless or threatened with homelessness (within 56 days), the local

authority will ask them to complete a HL1 form. This form includes a question on whether the applicant/

s have been sleeping rough. As well as information on homeless applicants, there is also a HL2

system which is used to collect a snapshot of households in temporary accommodation at the end of

each quarter. Homeless applicants may be placed in temporary accommodation whilst local authorities

assess their applications, or if they are waiting for a permanent let. Since 2016, it has been mandatory

for local authorities to submit placement level data on temporary accommodation which has formed the

HL3. The Scottish Government collects this information from all 32 local authorities which is fed

through the various systems and is then formulated into bi-annual statistical releases[20]

. The Prevent1

data collection gathers information on the operation of ‘Housing Options’ services that are made

available when households seek assistance for housing-related issues, and which can be used by

local authorities as a means of delivering statutory duties around the provision of advice and

information for the prevention of homelessness. It is not built into legislation, but aims to provide

guidance on housing issues to those at risk of homelessness.

In Northern Ireland, the Northern Ireland Housing Executive (NIHE) is a non-departmental public

body, for which the Department for Communities (DfC) acts as a sponsor body. NIHE has sole

responsibility for homelessness assessments and provision of housing. NIHE records data on those

who present as homeless, and within that, those who are ‘accepted as full duty applicants’. ‘Full duty

applicants’ have been assessed using four tests; these tests assess whether the applicant is homeless

or threatened with homelessness, ‘eligible for assistance’, ‘unintentionally homeless’, and in ‘priority

need’. This data is then collected by NIHE, and analysed and published by DfC. DfC then produces an

annual compendium of statistics relating to housing. This annual report includes data on those

‘presenting as homeless’, those ‘accepted as full duty applicants’, those ‘rejected’ and those

‘discharged’[21]

. NIHE and the DfC also produce quarterly ‘Housing Bulletins’ containing information on

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homelessness and housing statistics[21]

. Placements in temporary accommodation are not currently

collected, but DfC are looking to include this in their statistics in the near future.

Prevention duties in Northern Ireland are covered in legislation, however, the statutory obligation is

limited in scope in comparison to legislation in England and Wales as NIHE must provide guidance to

help those threatened with homelessness within 28 days. This is covered by the Housing Options

Model, implemented as Housing Solutions and Support, which increased and improved front line

services in Housing through a major programme of training and development, and a new structure of

frontline ‘housing advisors’. The Housing Options Model was piloted from 2014, and is now fully

operational as of June 2018. The focus is on early intervention, and examines an individual’s

circumstances and choices when they seek housing advice to ensure appropriate guidance is provided

to prevent them from becoming homeless.

In England the Rough Sleepers Strategy 2018 sets out a 2027 vision to end rough sleeping[22]

.

MHCLG publishes statistics on rough sleeping through an annual rough sleeper count[23]

. The count is

conducted by local authorities and verified by Homeless Link on behalf of MHCLG. Local Authorities

can decide whether they conduct a count, an estimate or a spotlight count which informs their

estimate. The rough sleeper count is taken during a single night between October and November.

The definition used to determine a rough sleeper for the count is:

This definition is similar to those used in Wales and Northern Ireland. There is also a Combined

Homelessness and Information Network (CHAIN database) maintained by St Mungo’s which reports

on rough sleepers for Greater London and uses Definition Two to describe rough sleeping. CHAIN is

a multi-agency database recording information about people sleeping rough and the wider street

population in London. CHAIN allows users to share information about work done with rough sleepers

and about their needs, ensuring that they receive the most appropriate support and that efforts are

not duplicated.

In Wales, similarly to England, rough sleepers are measured through a rough sleeper count. The

rough sleeping definition for Wales is the same as Definition Two. Since 2015, statistics are published

on rough sleepers annually in February and include the number of available emergency bed spaces

on the night of the count[25]

. The information is collected through a two-week exercise requiring local

authorities to gather information in partnership with local agencies in October (phase 1) followed by a

one-night count carried out in November (phase 2)[25]

. Rough sleeper information is published every

February.

In Scotland, information gathered through the HL1 form is used to calculate Scotland’s rough sleeper

statistics, which is related only to those who have contacted Local Authorities and submitted a

Definition Two: rough sleeper count

“People sleeping, about to bed down (sitting on/in or standing next to their bedding) or actually bedded down

in the open air (such as on the streets, in tents, doorways, parks, bus shelters or encampments). People in

buildings or other places not designed for habitation (such as stairwells, barns, sheds, car parks, cars, derelict

boats, stations, or ‘bashes’).”[24]

3.2 Rough sleeping statistics

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The differences in legislation will also mean that homelessness statistics are not directly comparable

across the UK (see section 2.2 on ‘Current legal definitions and how they differ’).

In conclusion, there are some distinctive differences between the data collection systems in

England, Wales, Scotland, and Northern Ireland. These affect the comparability of statistics

across the four nations:

Each UK nation produces information on homeless applicants and outcomes. However,

information about the total number of homeless applications is not available in Wales as

applications could be double counted if more than one outcome is given.

In England, all local authorities either carry out a rough sleeper count, an estimate, or a

spotlight rough sleeper count which informs their estimate.

In Wales, all local authorities carry out a two-week exercise and a one-night rough

sleepers count.

In Scotland, information on rough sleepers is collected through administrative means and

therefore only includes those applying for help through a local authority.

Northern Ireland produce a rough sleeper count but this is for their larger cities only and

does not cover the whole population.

homelessness application. Scotland have a more succinct definition of rough sleeping (Definition

Three).

This definition is less descriptive than other UK definitions of homelessness as the method for

collecting data on rough sleepers is through the local authority administrative system instead of an

estimated rough sleeper count.

In Northern Ireland, NIHE carries out an annual rough sleeping street count in Belfast and Newry, in

collaboration with the Welcome Organisation[27]

. The 2018 count has also been extended to Derry/

Londonderry. Through consultation with their local offices and police, NIHE has identified that rough

sleeping is not a substantial issue outside of their larger cities, and so, rough sleeper counts have

been focussed on larger urban areas such as Belfast. NIHE’s rough sleeper count methodology

follows a similar “snapshot” approach to that undertaken by England and uses the same definition of

rough sleeping (Definition Two). While the street count does not cover the whole population, the

Housing Executive’s data for 2018 will include estimates in areas where a street count is not carried

out.

Definition Three: rough sleeping (Scotland)

“Sleeping outside, either in the open air (such as on the streets or in doorways, parks or bus shelters), or in a

building or other place not designed for habitation (such as barns, sheds, car parks, cars, derelict boats,

stations etc.)”[26]

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There are different definitions of homelessness in use across the UK for legal, statistical and

operational purposes. We have investigated devolved definitions of homelessness as well as

definitions of homelessness used by other government departments (see Annex D). Additionally, we

explored third sector and academic definitions of homelessness (see Annex E). We have identified

definitions used for non-statistical purposes to better understand the full landscape of the use and

collection of homelessness information.

In order to provide users with a clearer understanding of the comparability of homelessness statistics

across the UK, the GSS Harmonisation Team explored the feasibility of creating a harmonised UK

definition of homelessness. Creating a harmonised definition that is fit for purpose would ensure

statistics are comparable across the UK, maximise the power of the data, and provide users with a

UK-wide common understanding of the topic instead of an understanding of each nation separately.

Harmonisation, which is different to standardisation, allows for small differences due to survey design

considerations and the complexity of administrative data. Standardisation requires data to be

completely uniform, whereas harmonisation recognises that there isn’t a “one size fits all” model so

data does not have to be produced and collected in the same way. A harmonised definition for

homelessness would enable users to better understand different types of homelessness, such as

rough sleeping and households in temporary accommodation.

There are a number of key challenges to creating a harmonised UK definition of homelessness for

UK official statistics. Different nations have their own definitions of homelessness as defined in law.

Although differences in devolved legislation are often overcome using harmonisation as opposed to

standardisation, legislation on homelessness has clear distinctions across the UK which limit the

comparability of the data collection methods. Data collection systems were developed independently

and collect information in different forms; such as case-level and aggregated datasets, which also

influences the statistics produced by UK nations on homelessness. To produce a definition that would

be workable for the four nations, the definition would need to encompass the different legislation and

data collection methods used across the UK.

The GSS Harmonisation Team has explored the possibility of utilising an existing definition to form

the basis of a UK harmonised definition for homelessness. However, we have concluded that current

definitions, although fit for individual purposes, would not meet all user requirements to form a UK

harmonised definition. Definitions are often country specific and do not incorporate legislative

differences across the devolved administrations. Therefore, if creating a harmonised definition for

homelessness, a new definition would need to be developed (taking previous research into account).

Our research has concluded that although a general definition for homelessness could be created,

developing a harmonised definition that government departments and the devolved administrations

could incorporate into their statistics is very challenging. All four nations collect information on rough

sleeping, homeless households and temporary accommodation, but differences in data collection

methods and in devolved legislation present significant barriers to creating a single definition for

4. Feasibility of harmonising UK definitions of homelessness

4.1 Conclusion

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homelessness. Additionally, administrative data systems for collecting homelessness information are

country-specific, and there would be significant costs in changing these processes in the near future.

Any consideration of increasing comparability across UK homelessness statistics would have to be

considered in the light of each country’s duty to meet the requirements of their direct data users.

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The OSR Systemic Review[1]

noted that users found the existing advice about the comparability of UK

homelessness statistics confusing. Here, we present research on how we can better support users to

understand how the statistics can be compared.

5.1 Statistical publication guidance

Guidance informing users about the comparability of homelessness statistics across the UK is included

in each nation’s statistical publication. Although each publication does go some way to providing a

narrative on UK comparability, there are inconsistencies. Improvements could be made to help users

understand the extent of comparability in UK homelessness statistics. The OSR Systemic Review

suggested that ‘statistics producers could improve the value of their statistics by being clearer on what

is measured, the extent to which it is comparable with related statistics, and the limitations of the

statistics’[1]

. In homelessness publications, England, Scotland and Wales provide a brief overview of

individual devolved legislation and data collections. Scotland goes one step further by providing a

cross-UK commentary on comparisons between the four nations. All four countries include links to the

other most recent releases in the UK. Each country approaches their statistical guidance differently so

there is a lack of consistency in commentary, therefore, users’ understanding of the extent to UK

comparability of homelessness statistics could be improved. To improve this guidance, statistics

producers could include more detailed descriptions of the extent of UK comparability, providing clarity

on the similarities and differences in data sources and helping users to understand the comparability of

homelessness statistics.

5.2 Conceptual framework for homelessness

As an alternative to creating a UK harmonised definition for homelessness, we explored the possibility

of creating a conceptual framework to address some of the difficulties of creating a single definition for

homelessness. A conceptual framework is an analytical tool used to explore a phenomenon where an

overall picture is needed. This conceptual framework would give users a visual representation of

homelessness definitions used across the UK and explain how these interact with one another and

relate to official statistics. The framework could identify the different concepts which relate to

homelessness such as rough sleeping and households in temporary accommodation. It would then

show distinctions in definitions used for similar concepts and identify the source each definition

originates from. Developing a framework allows more flexibility than creating a harmonised definition

as it can incorporate different subsets of homelessness. This would enable users to visualise the

different definitions of homelessness used across the UK, how they relate to one another and the level

of comparability currently possible.

5. Opportunities for improving users’ understanding of the

comparability of homelessness statistics

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The key purpose of this report is to investigate the feasibility of developing a harmonised definition of

homelessness for UK official statistics. Additionally, the report has evaluated different ways to improve

users’ understanding of the comparability of UK homelessness statistics. The GSS Harmonisation

Team spoke to many stakeholders across academia, the third sector and the GSS to gather a detailed

knowledge of the differences in legislation, data collection, statistics and definitions of homelessness

across the UK (see Annexes D and E). On this basis, we recommend the below short and long-term

actions be undertaken to improve user understanding of the comparability of UK homelessness

statistics.

In the short-term, the guidance provided about homelessness statistics could be improved to explain

how the different data sources can and cannot be compared. Statistical publications on homelessness

are high profile releases and we have identified a user need for a better understanding of how

comparable the different nations’ statistics are. Therefore, by Summer 2019, we propose to work with

the four nations to:

1. Develop more comprehensive guidance on the processes and definitions used in each

publication. This will help users to better understand the processes and legislation behind the

different statistics. Each nation’s publications on homelessness currently approach statistical

guidance in a different way which could be improved to be more coherent and consistent. We will

work with UK producers of homelessness statistics to agree consistent guidance for all four UK

nations which can be included in their statistical publications.

2. Create a separate, user-friendly paper on the comparability of homelessness statistics

which will include a conceptual framework for homelessness. This standalone report will

include a description of UK comparability and UK homelessness publications will link to it. It will

set out a conceptual framework which will allow users to visualise the different definitions of

homelessness currently being used for official statistics and how these fit together. The

framework will identify the different concepts which relate to homelessness and show distinctions

in definitions used for similar concepts. The GSS Harmonisation Team will engage with

stakeholders to define the scope and develop the framework. This will act as a short-term

solution to some of the difficulties of creating a UK harmonised definition for homelessness.

Due to the challenges in harmonising homelessness statistics across the UK, a priority for the GSS

Harmonisation Team is to improve users’ understanding of the comparability of homelessness

statistics by creating a conceptual framework and improving publication guidance. However, in the

long-term:

3. It is important that across the Government Statistical Service we consider what are the big

questions around homelessness in the UK and whether some of that requires coordinated

working across each UK country, and to consider how data can be collated to answer

those questions. Statutory homelessness data is driven by legislation in each UK nation, as is

appropriate in a devolved context. However, statistics producers can still continue to explore

alternative ways to improve UK comparability. Consideration should be given to how the barriers

to harmonisation that we have identified could be overcome, including an assessment of the

costs and resources associated with providing users with information on the size of the

6. Recommendations

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differences, or guidance on how to make adjustments to obtain comparable estimates. To

assist in this longer-term goal to improve the harmonisation of UK homelessness statistics, we

have outlined the key differences between the sources and the reasons for those differences

throughout this report.

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The GSS Harmonisation Team will continue to have an active role in taking forward the above

recommendations to improve users’ understanding of the comparability of UK homelessness

statistics. We expect to work closely with a range of stakeholders to assist us in this work. We will

continue to engage with users and producers of statistics to ensure our overall aim of providing clarity

on the comparability of homelessness statistics is met. We will work collaboratively with the four

nations to create harmonised statistical publication guidance and to produce the separate standalone

report. This work will be led and facilitated by the GSS Harmonisation Team and we envisage that

the statistical guidance and standalone report will be completed by Summer 2019.

Contact Information

If you have any comments or queries about this report, please get in touch

with the GSS Harmonisation Team at [email protected]

If you would like to find out more about the GSS Harmonisation Team

please visit: https://gss.civilservice.gov.uk/guidances/harmonisation/

For information on Best Practice and Impact Division: https://gss.civilservice.gov.uk/about-us/support-

for-the-gss/

7. Next steps

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8. Annex A: Organisations that contributed to this report

We would like to extend our thanks to everyone who took the time to talk to us and helped to shape

the development of this report:

Cabinet Office

Cardiff University

Centre for Homeless Impact

Crisis

Department for Education

Department for Health and Social Care

Department for Work and Pensions

European Federation of National Organisations Working with the Homeless (FEANTSA)

Heriot Watt University

Homeless Link

Home Office

National Records of Scotland

NHS Digital

NHS England

NHS FIFE

Northern Ireland Department for Communities

Northern Ireland Housing Executive

Ministry for Housing, Communities and Local Government

Ministry for Justice

Office for National Statistics

Office for Statistics Regulation

Pathway

Public Health England

Scottish Government

Shelter England

Shelter Scotland

St. Mungos

Welsh Government

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9. Annex B: Definitions of priority need

9.1 Annex B1: The Housing (Homeless Persons) Act 1977[3]

(1) For the purposes of this Act a homeless person or a person threatened with homelessness has a

priority need for accommodation when the housing authority are satisfied that he is within one of the

following categories:—

(a) he has dependent children who are residing with him or who might reasonably be expected

to reside with him;

(b) he is homeless or threatened with homelessness as a result of any emergency such as

flood, fire or any other disaster;

(c) he or any person who resides or might reasonably be expected to reside with him is

vulnerable as a result of old age, mental illness or handicap or physical disability or other

special reason.

(2) For the purposes of this Act a homeless person or a person threatened with homelessness who is

a pregnant woman or resides or might reasonably be expected to reside with a pregnant woman has a

priority need for accommodation.

(3) The Secretary of State may by order, made after appropriate consultations,—

(a) specify further categories of persons as having a priority need for accommodation, and

(b) amend or repeal any part of subsection (1) or (2) above.

(4) No order under subsection (3) above shall be made unless a draft of the order has been approved

by resolution of each House of Parliament.

(5) Any reference in this Act to a person having a priority need is a reference to his having a priority

need for accommodation within the meaning of this section or any order for the time being in force

under subsection (3) above.

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9.2 Annex B2: Section 70 of the Housing Act 199612]

The priority need categories are defined in Section 70 of the Housing Act 1996 and set out in the

Homelessness Code of Guidance. The categories of priority need are as follows:

• a pregnant woman;

• a person with whom dependent children reside;

• a person who is vulnerable as a result of old age, mental illness or handicap or physical disability

or other special reason;

• a person who is homeless or threatened with homelessness as a result of an emergency such

as flood, fire or other disaster;

• a care leaver or person at particular risk of sexual or financial exploitation, 18 years or over but

under the age of 21;

• a 16 or 17 year old;

• a person fleeing domestic abuse or threatened domestic abuse;

• a person homeless after leaving the armed forces; and

• a former prisoner who is vulnerable as a result of having served a custodial sentence.

Where more than one priority need category applies the one category which was most crucial in determining priority need should be recorded

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9.3 Annex B3: The Housing (Northern Ireland) Order 1988[10]

For the purposes of the above Order, a homeless person or a person threatened with homelessness

has a priority need for accommodation if the Housing Executive is satisfied that he is within one of

the following categories

The following have a priority need for accommodation—

(a) a pregnant woman or a person with whom a pregnant woman resides or might reasonably be

expected to reside;

(b) a person with whom dependent children reside or might reasonably be expected to reside;

(c) a person who is vulnerable as a result of old age, mental illness or handicap or physical disability

or other special reason, or with whom such a person resides or might reasonably be expected to

reside;

(d) a person who is homeless or threatened with homelessness as a result of an emergency such as

a food, fire or other disaster;

(e) a person without dependent children who satisfies the Executive that he has been subject to

violence and is at risk of violent pursuit or, if he returns home, is at risk of further violence;

(f) a young person who satisfies the Executive that he is at risk of sexual or financial exploitation.

(2) In paragraph (1)( f) “young person” means a person who is over compulsory school age (within

the meaning of Article 46 of the Education and Libraries (Northern Ireland) Order 1986F1) and has

not attained the age of 21 years.

(3) The Department may by order made subject to affirmative resolution—

(a) specify further descriptions of persons as having a priority need for accommodation, and

(b) amend or revoke any part of paragraph (1) or (2).

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10. Annex C: Definitions of intentionally homeless

10.1 Annex C1: The Housing Act 1996[12]

(1) A person becomes homeless intentionally if he deliberately does or fails to do anything in

consequence of which he ceases to occupy accommodation which is available for his occupation and

which it would have been reasonable for him to continue to occupy.

(2) For the purposes of subsection (1) an act or omission in good faith on the part of a person who

was unaware of any relevant fact shall not be treated as deliberate.

(3) A person shall be treated as becoming homeless intentionally if—

(a)he enters into an arrangement under which he is required to cease to occupy

accommodation which it would have been reasonable for him to continue to occupy, and

(b)the purpose of the arrangement is to enable him to become entitled to assistance under this

Part,

and there is no other good reason why he is homeless.

(4) A person who is given advice or assistance under section 197 (duty where other suitable

alternative accommodation available), but fails to secure suitable accommodation in circumstances in

which it was reasonably to be expected that he would do so, shall, if he makes a further application

under this Part, be treated as having become homeless intentionally.

In deciding what steps the local housing authority must take when someone applies for housing, the

authority must be satisfied that the applicant did not become homeless intentionally.

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10.2 Annex C2: The Housing (Wales) Act 2014[4]

(1) A person is intentionally homeless for the purpose of this Chapter if subsection (2) or (4) apply.

(2) This subsection applies if the person deliberately does or fails to do anything in consequence of

which the person ceases to occupy accommodation which is available for the person’s occupation and

which it would have been reasonable for the person to continue to occupy.

(3) For the purposes of subsection (2) an act or omission in good faith on the part of a person who

was unaware of any relevant fact may not be treated as deliberate.

(4) This subsection applies if—

(a) the person enters into an arrangement under which the person is required to cease to

occupy accommodation which it would have been reasonable for the person to continue to

occupy, and

(b) the purpose of the arrangement is to enable the person to become entitled to help under

this Chapter,

and there is no other good reason why the person is homeless.

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10.3 Annex C3: Housing (Northern Ireland) Order 1988[10]

(1) A person becomes homeless intentionally if he deliberately does or fails to do anything in

consequence of which he ceases to occupy accommodation, whether in Northern Ireland or

elsewhere, which is available for his occupation and which it would have been reasonable for him

to continue to occupy.

(2) A person becomes threatened with homelessness intentionally if he deliberately does or fails to do

anything the likely result of which is that he will be forced to leave accommodation which is

available for his occupation and which it would have been reasonable for him to continue to

occupy.

(3) For the purposes of paragraph (1) or (2) an act or omission in good faith on the part of a person

who was unaware of any relevant fact shall not be treated as deliberate.

(3A) A person shall be treated as becoming homeless intentionally, or as becoming threatened

with homelessness intentionally, if—

(a) he enters into an arrangement under which he is required to cease to occupy

accommodation which it would be reasonable for him to continue to occupy, and

(b) the purpose of the arrangement is to enable him to become entitled to assistance under

this Part,

and there is no other good reason why he is homeless.

(4) Regard may be had, in determining whether it would have been reasonable for a person to

continue to occupy accommodation, to the general circumstances prevailing in relation to housing

in Northern Ireland.

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11. Annex D: Other Government departments’ definitions of

homelessness

During our stakeholder engagement, the following departments were identified as using definitions of

homelessness in an operational sense. These definitions are not used to publish data on statutory

homelessness or rough sleeping. This information was collected via conversations with government

departments on how they use homelessness definitions in practice. The departments, do not,

however, produce official statistics on homelessness.

The Department for Work and Pensions (DWP) records information on homelessness in

operational systems including the claimant profile under Universal Credit. This information is recorded

‘free text’ by Jobcentre work coaches to enable them to best support the individual needs of the

claimant. This information is used for internal monitoring only and is not statistically robust or suitable

for external use. DWP uses MHCLG’s regular H-CLIC data series on statutory homelessness and

their annual rough sleeping count to inform policy development.

The Department for Education (DfE) collect homelessness data relating to Children’s Services,

specifically ‘Care Leavers’. Between the ages of 17 and 21, data is collected on those who leave

government care. Usually the care worker, who is assigned to a Care Leaver collects the data which

includes accommodation and therefore determines whether a person is homeless/no fixed abode or

not. DfE do not have a legislative or operational definition of homelessness, instead a list of

accommodation options where the most suitable is chosen.

The Department for Health and Social Care with NHS England collect data on homelessness. This

data is collected during hospital discharge, asking where people are going after their hospital stay,

and what their housing status is. This is used for service provision.

NHS services collect some data on the current accommodation of a patient. This includes several

classifications, including: “homeless”, “rough sleeper”, “squatting”, “night shelter/emergency hostel

(temporary accommodation)”, “staying with friends/family as a short-term guest”, and “other

homeless”. This data is transferred to NHS Digital where it is processed. Discussions are underway to

improve collection of homelessness information in the health system.

The Ministry of Justice (MoJ) collect data for accommodation status of offenders released from

prison, and those under probation supervision. Data are published quarterly on the proportion of

offenders in “settled” accommodation under the supervision of Community Rehabilitation Companies

(private probation providers). They have also released an ad-hoc bulletin on the accommodation

circumstances of all offenders both post release and on community sentences. For 2019/20, MoJ

intends to launch new performance measures on the proportion of offenders released to

accommodation and on termination of probation supervision which will be subsequently published as

part of Ministry’s performance statistics, subject to data quality.

MoJ defines homelessness based on the legal definition, with three categories; rough sleeping,

squatting, and homeless other. It defines settled accommodation as any accommodation that provides

a permanent independent housing solution for a minimum of three months.

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12. Annex E: Third sector and academic definitions of

homelessness

In addition to the definitions used by the devolved administrations, MHCLG and other Government

departments, there are a number of other definitions in use. Notably, these include ETHOS

(developed by FEANTSA), Core/Wider Homelessness (developed by Prof. Suzanne Fitzpatrick and

Prof. Glen Bramley from Heriot Watt University in collaboration with Crisis), and the Framework of

Global Homelessness (proposed by Prof. Volker Busch-Geertsema, Prof. Dennis Culhane, and Prof.

Suzanne Fitzpatrick with the Institute of Global Homelessness [IGH]).

ETHOS[28]

: The European Federation of organisations working with the people who are homeless

(FEANTSA), has developed a European Typology of Homelessness and housing exclusion (ETHOS).

The ETHOS typology begins with the conceptual understanding that there are three domains which

constitute a home, and the absence of these can be taken to define homelessness.

Core/Wider[29]

: This definition of homelessness was created with a GB outlook and aims to capture

two specific categories. “Core homelessness” refers to households who are considered homeless at

any point in time due to experiencing the most acute forms of homelessness or living in short-term or

unsuitable accommodation. “Wider homelessness” refers to those at risk of homelessness or who

have already experienced it and are in accommodation which is on a temporary basis. This definition

is used as part of a ‘homelessness projections’ report which summaries statistics on homelessness

across GB.

Framework of Global Homelessness[30]

: Proposed by the Institute for Global Homelessness, the

‘Framework of Global Homelessness’ draws upon ETHOS, developing world contexts and recent

critiques of ETHOS. The core concept at the heart of the definition is homelessness as “lacking

access to minimally adequate housing”, and the framework contains three broad categories; people

without accommodation, people living in temporary or crisis accommodation, and, people living in

severely inadequate and insecure accommodation.

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13. Annex F: References

[1] Office for Statistical Regulation (OSR) Systemic Review of Public Value: Statistics on Housing and

Planning in the UK, November 2017. Available at: https://www.statisticsauthority.gov.uk/wp-content/

uploads/2017/11/Systemic-Review-of-Statistics-on-Housing-and-Planning-in-the-UK20171110-

corrected.pdf

[2] Cross Government Housing and Planning Statistics Work Programme, May 2018: Page 2. Available at:

https://blog.ons.gov.uk/wp-content/uploads/sites/6/2019/05/HousingWorkProgrammeMay2018.pdf

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[22] Ministry of Housing, Communities and Local Government: The rough sleeping strategy. Available at:

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[23] Homeless Link, September 2018. Counts and Estimates Toolkit 2018. Available at: https://

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[24] Ministry of Housing, Communities and Local Government, 25th January 2018. Rough sleeping in

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[29] Glen Bramley (August 2017) Homelessness projections: Core homelessness in Great Britain. Crisis and

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